file:///J|/INITENG/P13%20cases/p130471.eng.txt[7/2/2013 7:28:31 AM] INITIAL REVIEW ENGINEERING REPORT PMN: 13-0471 Focus Ready Draft 6/17/2013

ENGINEER: Hall \ REC PV (kg/yr): 33,000

SUBMITTER: H.B.Fuller Company

USE: Curable binder resin for adhesive used to manufacture flexible packaging. Stepan Co. has provided the identity of feedstock No references found. Isocyanate FGEW = 869.

OTHER USES: Analogs adhesives for laminating textiles; Analog reactive hot melt adhesive for substrate lamination.

MSDS: Yes Label: No

Gen Eqpt: Wear safety glasses. // Wear chemically resistant gloves and long sleeved shirt. // Use local exhaust ventilation or other engineering controls to minimize exposure. Respirator: Use a respirator if general room ventilation is not available or sufficient to eliminate symptoms. NIOSH approved air purifying respirator with organic vapor cartridge. Health Effects: Eyes: Can cause irritation. / Skin: Can cause moderate skin irritation, defatting, and dermatitis. Not likely to cause permanent damage. May cause sensitization. // Inhalation: Can cause moderate respiratory irritation. May cause allergic respiratory reaction. Other possible symptoms include: wheezing and coughing due to pulmonary edema (fluid build-up in lungs). If product is heated or if an aerosol/mist is generated, airbone concentrations may be reached that cause irritation or other adverse effects. Inhalation of high concentrations may result in central nervous system (CNS) effects such as dizziness, weakness, fatigue, nausea, headache, and lack of coordination. // Ingestion: Harmful if swallowed. Ingestion is not an anticipated route of exposure. Irritating to mouth, throat, and stomach. // Chronic Effects: May cause tumors based on tests with laboratory animals. // Target Organs: Lungs, Skin. TLV/PEL: Ethyl Acetate (CASRN 141-78-6) 30 wt% 400 ppm TWA ACGIH Exposure Limits Ethyl Acetate (CASRN 141-78-6) 30 wt% 400 ppm TWA OSHA PEL Ethyl Acetate (CASRN 141-78-6) 30 wt% 1400 mg/m3 TWA OSHA PELfile:///J|/INITENG/P13%20cases/p130471.eng.txt[7/2/2013 7:28:31 AM] Methylene Bisphenyl Diisocyanate (MDI) (CASRN 101-68-8) 5 wt% 0.005 ppm TWA (listed under Methylene bisphenyl isocyanate (MDI)) ACGIH Exposure Limits Methylene Bisphenyl Diisocyanate (MDI) (CASRN 101-68-8) 5 wt% 0.02 ppm Ceiling OSHA PEL Methylene Bisphenyl Diisocyanate (MDI) (CASRN 101-68-8) 5 wt% 0.2 mg/m3 Ceiling OSHA PEL

CRSS (06/06/2013): Chemical Name: Soybean oil, polymer with diethylene glycol, dipropylene glycol, 1, 1'-methylenebis[4-isocyanatobenzene], phthalic anhydride, polypropylene glycol and polypropylene glycol ether with glycerol (3:1) S-H20: Reacts g/L @ VP: 1.0E-6 torr @ MW: 1737.00 5.57%<500 10.17%<1000 Physical State and Misc CRSS Info: Neat: Solid Mfg: Solution: 72.62% PMN substance in formulation Proc/Form: Solution: 68.5% PMN substance in formulation End Use: Destroyed. A letter of support was submitted by the Stepan Company, which provides the PMN case number and identity of the third feedstock known by the tradename Stepanol PD-110LV. MW NAVG = 1737 with 5. 57% < 500 and 10.17% < 1000, by GPC. Submitted Data: Solid; negligible solubility in water; density = 1.07 g/cm3. Estimated Data: BP > 500°C (High MW); VP < 0. 000001 torr (High MW); reacts with water (isocyanate). Isocyanate FGEW = 1737/2 = 869. The substance will hydrolyze with water with a half-life of hr-days to yield the structure with NH2 groups in place of the terminal N=C=O groups. Cont'd on p.6.

Consumer Use: No

SAT (concerns) (06/07/2013): Related Cases and Related Cases and Misc SAT Info: Ecotox: Analogs: Migration to groundwater: Hyd Pdt negl PBT rating: P3B1T1 PMN - P1B1T1 // Hyd Pdt - P3B1T1 Health: 1-2 Dermal, Inhalation Eco: 1 No releases to Water

OCCUPATIONAL EXPOSURE RATING: 2B

NOTES & KEY ASSUMPTIONS: Generated by the 06/07/2005 version of ChemSTEER.file:///J|/INITENG/P13%20cases/p130471.eng.txt[7/2/2013 7:28:31 AM] POLLUTION PREVENTION CONSIDERATIONS: P2 Claims: Food packaging reduction relieves our need for glass, steel and paper as well as transportation and manufacturing costs. This new polymer is a high solids, low solvent, low usage volume product that will reduce food containment costs. It also has improved bond strength and is food safe within 3 days.

EXPOSURE-BASED REVIEW: No

INITIAL REVIEW ENGINEERING REPORT PMN: 13-0471

Manufacturing: Batch

Number of Sites/ Location: 2 H.B. Fuller Company Grand Rapids MI 49544-1198 H.B. Fuller Company Pilot Facility St. Paul MN 55110 Days/yr: 3 Basis: Submitter specifies 2 sites, 6,136 kg/bt, 12 hrs/bt, 3 bt/yr, and 72.62% PMN in formulation. Due to a mass balance discrepancy, CEB assumes 3 bt/site-yr and CS calculates a use rate of 5,500 kg/st-bt.

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY IRER Note: The daily releases listed for any source below may coincide with daily releases from the other sourcesfile:///J|/INITENG/P13%20cases/p130471.eng.txt[7/2/2013 7:28:31 AM] to the same medium. Submitter estimates a release of 0.10 kg/bt from QC Sampling, 0.5 kg/bt from Filter Change Out, and 10 kg/yr from Cleanup; all releases are disposed of via landfill. Environmental releases are not assessed for this IRER as the triggers for assessment were not met. Note: Water - not required, per SAT; Land - migration to groundwater negl. and drinking water is not a concern; Incin - potential releases <28,000 kg/site-day; and Air - <0.54 kg/site-day and PMN is non-volatile (VP << 0.01 torr).

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 6 Basis: Submission estimates exposure for up to 4 total workers. CEB assumes 3 workers/site and that all workers conduct all activities.

Inhalation: negligible (VP < 0.001 torr)

Dermal:

Exposure to Liquid at 72.62% concentration High End: 1.3E+3 mg/day over 3 days/yr Number of workers (all sites) with dermal exposure: 6 Basis: Loading Liquid Product into Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

INITIAL REVIEW ENGINEERING REPORT PMN: 13-0471

Use: Curable Binder Resin

Number of Sites/ Location: 1 Sonoco Eau Claire WI Days/yr: 260 Basis: Submitter specifies 1 site, 260 days/yr operation (CEB assumes the number of exposure days is equivalent to operating days), and the adhesive formulation arrives as 72.62% PMN. CS calculates a use rate of 126.92 kg/st-bt.file:///J|/INITENG/P13%20cases/p130471.eng.txt[7/2/2013 7:28:31 AM] ENVIRONMENTAL RELEASES ESTIMATE SUMMARY IRER Note: The daily releases listed for any source below may coincide with daily releases from the other sources to the same medium. Submitter estimates the following releases: 1 kg/bt from container residue and 5 kg from equipment cleaning; all wastes are cured to a water insoluble solid and landfilled. Environmental releases are not assessed for this IRER as the triggers for assessment were not met. Note: Water - not required, per SAT; Land - migration to groundwater negl. and drinking water is not a concern; Incin - potential releases <28, 000 kg/site-day; and Air - <0.54 kg/site-day and PMN is non-volatile (VP << 0.01 torr).

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 3 Basis: Submitter estimates exposure for up to 2 workers. CEB assumes default minimum of 3 workers/site and that all workers conduct all activities.

Inhalation:

Exposure to Particulate (Class I) Low End of Range: 4.0E-1 mg/day over 250 days/yr High End of Range: 2.6E+0 mg/day over 250 days/yr Number of workers (all sites) with inhalation exposure: 3 Basis: Roll Coating; EPA/OPPT UV Roll Coating Inhalation Model (non-volatiles); airborned particulate concentration (KcK is based on 8-hour TWA personal monitoring data. NOTE: The respirator class is: I. Particulate (including solid or liquid droplets).

INHALATION MONITORING DATA REVIEW 1) Uncertainty (estimate based on model, regulatory limit or data not specific to industry): Yes 2)a) Exposure level > 1 mg/day? Yes OR b) Hazard Rating for health of 2 or greater? 1-2 No Inhalation Monitoring Data Desired? Yes (both criteria met)file:///J|/INITENG/P13%20cases/p130471.eng.txt [7/2/2013 7:28:31 AM] Dermal:

Exposure to Liquid at 72.62% concentration High End: 1.3E+3 mg/day over 250 days/yr Number of workers (all sites) with dermal exposure: 3 Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.